CLA-2-84:S:N:N1:103 873367
Mr. Anthony Duryea
Davy McKee Corporation
One Oliver Plaza
Pittsburgh, PA 15222-2682
RE: The tariff classification of a ladle shroud manipulator
robot from the United Kingdom
Dear Mr. Duryea:
In your letter dated April 9, 1992 you requested a tariff
classification ruling.
The ladle shroud manipulator robot is mounted onto a work
platform erected next to the continuous caster. The ladle shroud
manipulator robot is used to grip a shroud (tube), rotate, and
place the shroud between a ladle and a tundish in order to
prevent air or other contaminants from coming into contact with
the molten steel. Once the shroud is properly positioned and
engaged onto the valve nozzle at the bottom of the ladle, the
liquid steel can flow into the tundish. Each time a new ladle
with molten steel is placed in the continuous caster, the robot
transfers and positions a new shroud so that the pour can
commence. The shrouds are stored in interchangeable racks which
are also located on the platform.
The robot controller allows the robot to be operated
manually, semi-automatically, or automatically. In the manual
mode the movements of the robot are controlled by means of two
joysticks. In the semi-automatic mode the robot automatically
transfers the shroud beneath the ladle, and the operator then
uses the joysticks to manipulate and engage the shroud onto the
ladle gate valve. Finally, in the automatic mode the robot
locates the ladle valve using a laser incorporated in the robot
and automatically positions and engages the shroud. According to
the information submitted with your letter, two robots and one
controller unit will be imported, with the second robot used as a
replacement for the working robot in the event of a breakdown.
You claim the ladle shroud manipulator robot should be
classified in the provision for parts of casting machines in
subheading 8454.90.0060, Harmonized Tariff Schedule of the United
States (HTS), and free of duty.
The General Rules of Interpretation provide the principles
which govern the classification of imported merchandise under the
HTS. GRI 1 states that classification of imported articles shall
be determined according to the terms of the headings and any
relative section or chapter notes. Note 2(a) to section XVI, the
section which encompasses casting machines and parts thereof,
states that parts which are goods included in any of the headings
of chapters 84 and 85 (other than headings 8485 and 8548) are in
all cases to be classified in their respective headings. Thus
the applicable subheading for the ladle shroud manipulator
robot(s), together with their controller, will be 8428.90.0010,
HTS, which provides for other lifting, handling, loading or
unloading machinery: other machinery: other: industrial robots.
The rate of duty will be 2 percent ad valorem.
This ruling is being issued under the provisions of Section
177 of the Customs Regulations (19 C.F.R. 177).
A copy of this ruling letter should be attached to the entry
documents filed at the time this merchandise is imported. If the
documents have been filed without a copy, this ruling should be
brought to the attention of the Customs officer handling the
transaction.
Sincerely,
Jean F. Maguire
Area Director
New York Seaport